Blower Door Testing Requirement in Collier County, FL

We recently received a phone call from a contractor in Collier County, FL about the blower door test requirement in his state. We’ve been covering this topic for a while, with the previous update coming from the Building Officials Association of Florida (BOAF). At that time, BOAF had made a statement that individuals possessing a BPI Certification would be deemed qualified to perform blower door testing per the state energy code requirement.

As with many things related to code enforcement, the question asked to BOAF, the BOAF answer, and the relevant code references are all somewhat vague and left open to interpretation.

Larry Zarker had submitted three questions to BOAF centered on whether an individual possessing "a relevant certification from the Building Performance Institute, Inc." would qualify a person to meet Florida’s code requirement for blower door testing from a certified third party.

Let’s take a moment to note that the Building Performance Institute (BPI) offers multiple certifications.

In fact, the BPI Infiltration & Duct Leakage Certification was created in 2014 to address air leakage testing in new construction homes and was broadly intended to satisfy up-and-coming state code requirements on this topic. That said, other common BPI certifications include BPI Building Analyst and BPI Envelope, which also address blower door testing but do NOT address duct testing.

The BPI Program is a national program that includes classroom and field training and examination.

The program to become a BPI rater has prerequisites before one is permitted to take the training.

BPI partners with the USDOE on rating existing homes.

BPI certified raters are subject to a quality control program.

The raters may only operate on code related items with the approval of the code official.

There is no requirement for a local jurisdiction to accept reports it does not believe are correct.

The program is an additional resource for departments that may not have the expertise to conduct increasingly complicated energy audits for new or existing construction."

Let’s also note that while there was a definitive YES answer, BOAF did not explicitly state which BPI designation would be accepted. If anything, these responses show support for BPI’s quality and places responsibility on the local code official to make the final determination of what’s acceptable.

We have been telling individuals coming to us for Florida blower door test certification to first check with their local code official to see what is accepted. Unfortunately, in most scenarios, the code official is also seeking clarification on what exactly the code is requiring and generally approves the certification that most translates to a blower door testing certification. In that case, one might think that the BPI Infiltration & Duct Leakage Certification was indeed the correct certification, because it focuses exclusively on blower door testing and results in a blower door testing certification.

Our Collier County phone caller that we originally spoke of, however, informed us that his local code enforcement official would not accept the BPI Infiltration & Duct Leakage Certification. Instead, his code official was suggesting BPI Building Analyst, BPI Envelope, or RESNET HERS Rater.

Having trained hundreds of contractors through Florida on blower door testing, this is the first instance where a code official has had specific demands on a qualifying certification.

So let’s dive into what the code actually says.

Examining the Florida Energy Code

"R402.4.1.2 Testing. The building or dwelling unit shall be tested and verified as having an air leakage rate of not exceeding 7 air changes per hour in Climate Zones 1 and 2, 3 air changes per hour in Climate Zones 3 through 8. Testing shall be conducted with a blower door at a pressure of 0.2 inches w.g. (50 Pascals). Testing shall be conducted by either individuals as defined in Section 553.993(5) or (7), F.S. or individuals licensed as set forth in Section 489.105(3)(f), (g), or (i) or an approved third party. A written report of the results of the test shall be signed by the party conducting the test and provided to the code official. Testing shall be performed at any time after creation of all penetrations of the building thermal envelope."

Bullet point 8 lists that "Blower Door Testing must be conducted by an Approved 3rd Party Certified Individual" which includes the following:

Design Professional

RESNET / BPI Certified Energy Auditor or Rater

Individuals licensed under FS 489.105(3) (f), (g), or (i) as

Class A Air Conditioning Contractor

Class B Air Conditioning Contractor

Mechanical Contractor

Alternative equivalent certifications will require pre-approval.**

**To obtain pre-approval, submit the proposal, including the certification curriculum, by email with the subject line "Pre-Approval" and send to BlowerDoorTests@colliercountyfl.gov

The company performing the Blower Door Test MUST be registered with the Growth Management Department, showing proof of licensure and/or certification, proof of liability insurance, workman’s compensation, and business tax receipt.

If you’re looking for more information about these occupational roles, see these definitions as outlined in FS 489.105(3) and FS 553.993 (5) and (7).

Approved 3rd Party Roles

And this is where things get a little bit dense…

FS 489.105(3) (f)"Class A air-conditioning contractor" means a contractor whose services are unlimited in the execution of contracts requiring the experience, knowledge, and skill to install, maintain, repair, fabricate, alter, extend, or design, if not prohibited by law, central air-conditioning, refrigeration, heating, and ventilating systems, including duct work in connection with a complete system if such duct work is performed by the contractor as necessary to complete an air-distribution system, boiler and unfired pressure vessel systems, and all appurtenances, apparatus, or equipment used in connection therewith, and any duct cleaning and equipment sanitizing that requires at least a partial disassembling of the system; to install, maintain, repair, fabricate, alter, extend, or design, if not prohibited by law, piping, insulation of pipes, vessels and ducts, pressure and process piping, and pneumatic control piping; to replace, disconnect, or reconnect power wiring on the load side of the dedicated existing electrical disconnect switch; to install, disconnect, and reconnect low voltage heating, ventilating, and air-conditioning control wiring; and to install a condensate drain from an air-conditioning unit to an existing safe waste or other approved disposal other than a direct connection to a sanitary system. The scope of work for such contractor also includes any excavation work incidental thereto, but does not include any work such as liquefied petroleum or natural gas fuel lines within buildings, except for disconnecting or reconnecting changeouts of liquefied petroleum or natural gas appliances within buildings; potable water lines or connections thereto; sanitary sewer lines; swimming pool piping and filters; or electrical power wiring. A Class A air-conditioning contractor may test and evaluate central air-conditioning, refrigeration, heating, and ventilating systems, including duct work; however, a mandatory licensing requirement is not established for the performance of these specific services.

FS 489.105(3) (g)"Class B air-conditioning contractor" means a contractor whose services are limited to 25 tons of cooling and 500,000 Btu of heating in any one system in the execution of contracts requiring the experience, knowledge, and skill to install, maintain, repair, fabricate, alter, extend, or design, if not prohibited by law, central air-conditioning, refrigeration, heating, and ventilating systems, including duct work in connection with a complete system only to the extent such duct work is performed by the contractor as necessary to complete an air-distribution system being installed under this classification, and any duct cleaning and equipment sanitizing that requires at least a partial disassembling of the system; to install, maintain, repair, fabricate, alter, extend, or design, if not prohibited by law, piping and insulation of pipes, vessels, and ducts; to replace, disconnect, or reconnect power wiring on the load side of the dedicated existing electrical disconnect switch; to install, disconnect, and reconnect low voltage heating, ventilating, and air-conditioning control wiring; and to install a condensate drain from an air-conditioning unit to an existing safe waste or other approved disposal other than a direct connection to a sanitary system. The scope of work for such contractor also includes any excavation work incidental thereto, but does not include any work such as liquefied petroleum or natural gas fuel lines within buildings, except for disconnecting or reconnecting changeouts of liquefied petroleum or natural gas appliances within buildings; potable water lines or connections thereto; sanitary sewer lines; swimming pool piping and filters; or electrical power wiring. A Class B air-conditioning contractor may test and evaluate central air-conditioning, refrigeration, heating, and ventilating systems, including duct work; however, a mandatory licensing requirement is not established for the performance of these specific services.

FS 489.105(3) (i)"Mechanical contractor" means a contractor whose services are unlimited in the execution of contracts requiring the experience, knowledge, and skill to install, maintain, repair, fabricate, alter, extend, or design, if not prohibited by law, central air-conditioning, refrigeration, heating, and ventilating systems, including duct work in connection with a complete system if such duct work is performed by the contractor as necessary to complete an air-distribution system, boiler and unfired pressure vessel systems, lift station equipment and piping, and all appurtenances, apparatus, or equipment used in connection therewith, and any duct cleaning and equipment sanitizing that requires at least a partial disassembling of the system; to install, maintain, repair, fabricate, alter, extend, or design, if not prohibited by law, piping, insulation of pipes, vessels and ducts, pressure and process piping, pneumatic control piping, gasoline tanks and pump installations and piping for same, standpipes, air piping, vacuum line piping, oxygen lines, nitrous oxide piping, ink and chemical lines, fuel transmission lines, liquefied petroleum gas lines within buildings, and natural gas fuel lines within buildings; to replace, disconnect, or reconnect power wiring on the load side of the dedicated existing electrical disconnect switch; to install, disconnect, and reconnect low voltage heating, ventilating, and air-conditioning control wiring; and to install a condensate drain from an air-conditioning unit to an existing safe waste or other approved disposal other than a direct connection to a sanitary system. The scope of work for such contractor also includes any excavation work incidental thereto, but does not include any work such as potable water lines or connections thereto, sanitary sewer lines, swimming pool piping and filters, or electrical power wiring. A mechanical contractor may test and evaluate central air-conditioning, refrigeration, heating, and ventilating systems, including duct work; however, a mandatory licensing requirement is not established for the performance of these specific services.

FS 553.993(5)"Energy auditor" means a trained and certified professional who conducts energy evaluations of an existing building and uses tools to identify the building’s current energy usage and the condition of the building and equipment.

FS 553.993(7)"Energy rater" means an individual certified by a building energy-efficiency rating system to perform building energy-efficiency ratings for the building type and in the rating class for which the rater is certified.

In short, the Florida energy code generally fails to name a specific certification. It lists and defines occupations and throws around words like "approved" and "certified."

Thankfully, the Collier County forms at least name one certification (RESNET). It sounds as though our phone caller had to dig a little deeper on the "BPI Certified Energy Auditor" title to hear that that phrase, in Collier County, refers to BPI Building Analyst or BPI Envelope, and not BPI Infiltration & Duct Leakage.

After reading the thorough explanations above of these job roles and finding that you still need to be certified in blower door testing, contact Everblue. We offer the following training and certification courses to help you meet Florida energy code: